spendthrift clause (Massachusetts) · Go Syfert
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spendthrift clause in Massachusetts

13 Massachusetts opinions name it 2 courts 1938–2018 0 in the last five years

The cases below were cited by Massachusetts courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
Davidson v. Davidsongreen
massappct · 1985 · cited in 3 Massachusetts opinions naming this issue, 1991–2002
2 sentences

2002In Davidson v. Davidson, 19 Mass. App. Ct. 364, 372-373 (1985), we held that a husband’s remainder interest in a trust, subject to survivorship and a spendthrift clause, was divisible under § 34.

2000L. c. 208, § 34); Davidson v. Davidson, 19 Mass. App. Ct. at 371-372 (husband’s remainder interest in a trust, subject to a spendthrift clause and the condition of survivorship, was divisible under G.

33
Lauricella v. Lauricellagreen
mass · 1991 · cited in 3 Massachusetts opinions naming this issue, 2000–2015
2 sentences

2015See Lauricella v. Lauricella, 409 Mass. 211, 216 (1991).

2000See Lauricella v. Lauricella, 409 Mass. at 216 (husband’s present beneficial interest in trust property, subject to a spendthrift clause, may be distributed pursuant to G.

23
Broadway National Bank v. Adamsgreen
mass · 1882 · cited in 2 Massachusetts opinions naming this issue, 1938–1988
2 sentences

1988Strandlund also asserts that a spendthrift provision restraining only involuntary alienation would be “unfairly prejudicial to creditors.” In Broadway Nat’l Bank v. Adams, 133 Mass. 170, 173-174 (1882), we addressed considerations of public policy with respect to a spendthrift clause that prohibited both voluntary and involuntary alienation.

1938We there adverted to the settled law of this Commonwealth sustaining the validity of spendthrift provisions for the protection of beneficiaries, citing Broadway National Bank v. Adams, 133 Mass. 170 , and many other cases, and we held that in endeavoring to enforce her decree for alimony the former wife stood "no better than any other creditor.” We are not asked to go over that ground again.

12
D.L. v. G.L.green
massappct · 2004 · cited in 1 Massachusetts opinions naming this issue, 2015–2015
2 sentences

2015See D.L. v. G.L., 61 Mass. App. Ct. 488, 496-497 (2004).

2015See D.L. v. G.L., 61 Mass. App. Ct. 488, 496-497 (2004).

11
Pemberton v. Pembertongreen
massappct · 1980 · cited in 1 Massachusetts opinions naming this issue, 2015–2015
2 sentences

2015She has no absolute right to the use of any part of the principal, and could herself compel principal payments only by showing that the trustees had abused their discretion by acting arbitrarily, capri ciously, or in bad faith”); Pemberton v. Pemberton, 9 Mass. App. Ct. 9, 20-21 (1980) (where, in case in which trust appears to have contained ascertainable standard, we stated, “if even apart from the spendthrift clause a trustee is given the discretionary power to distribute income or principal to described beneficiaries ‘any right of any beneficiary to receive anything is subject to the condit

2015She has no absolute right to the use of any part of the principal, and could herself compel principal payments only by showing that the trustees had abused their discretion by acting arbitrarily, capriciously, or in bad faith"); Pemberton v. Pemberton, 9 Mass. App. Ct. 9, 20-21 (1980) (where, in case in which trust appears to have contained ascertainable standard, we stated, "if even apart from the spendthrift clause a trustee is given the discretionary power to distribute income or principal to described beneficiaries, 'any right of any beneficiary to receive anything is subject to the condit

11
Town of Randolph v. Robertsgreen
mass · 1964 · cited in 1 Massachusetts opinions naming this issue, 1996–1996
1 sentence

1996See Randolph, supra at 579-580 .

11
Wolfe v. Wolfegreen
massappct · 1985 · cited in 1 Massachusetts opinions naming this issue, 1991–1991
1 sentence

1991See Wolfe v. Wolfe, 21 Mass. App. Ct. 254, 256-257 (1985) (holding that, where husband was cosettlor and co-trustee, trust principal may be invaded under § 34 to satisfy alimony obligation); Davidson v. Davidson, supra at 371-372 (holding that husband’s remainder interest in a trust, subject to a spendthrift clause and the condition of survivorship, was divisible under § 34). 3 *215 Beyond § 34 and Massachusetts precedents, review of the opinions of other States that have considered this or analogous questions reveals no clear consensus.

11
Greenwich Trust Co. v. Tysongreen
conn · 1942 · cited in 1 Massachusetts opinions naming this issue, 1980–1980
1 sentence

1980See Greenwich Trust Co. v. Tyson, 129 Conn. 211 (1942); Constanza v. Verona, 48 N.J.

11
Dunn v. Sargentgreen
mass · 1869 · cited in 1 Massachusetts opinions naming this issue, 1972–1972
1 sentence

1972See Dunn v. Sargent, 101 Mass. 336, 339-340 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Massachusetts. Read the followed side critically anyway.

Also cited on this issue (6)

CaseCitedYears
Speed v. Speed green
ga · 1993
2 sentences

2018In a case with remarkably similar facts insofar as a husband involved in a motor vehicle accident causing serious injuries placed proceeds of his personal injury action into a spendthrift trust, the Georgia Supreme Court said "no settlor, disabled or otherwise, should be permitted to put his own assets in a trust, of which he is the sole *693 beneficiary, and *468 shield those assets with a spendthrift clause, because to do so is 'merely shift[ing] the settlor's assets from one pocket to another, [in an attempt to avoid creditors].' " Speed v. Speed , 263 Ga. 166 , 168, 430 S.E.2d 348 (1993),

2018In a case with remarkably similar facts insofar as a husband involved in a motor vehicle accident causing serious injuries placed proceeds of his personal injury action into a spendthrift trust, the Georgia Supreme Court said "no settlor, disabled or otherwise, should be permitted to put his own assets in a trust, of which he is the sole *693 beneficiary, and *468 shield those assets with a spendthrift clause, because to do so is 'merely shift[ing] the settlor's assets from one pocket to another, [in an attempt to avoid creditors].' " Speed v. Speed , 263 Ga. 166 , 168, 430 S.E.2d 348 (1993),

12018–2018
Bongaards v. Millen green
massappct · 2002
1 sentence

2003Under that rule, however, the trust property at issue here is still not subject to the plaintiff’s elective share for the simple reason that the trust was created by a third party, D’Amore, and not by Jean. 4 The rule announced in Sullivan applies only to assets of a trust “created during the marriage by the deceased spouse.” Id. at 872 .

12003–2003
Constanza v. Verona green
njsuperctappdiv · 1958
1 sentence

1980See Greenwich Trust Co. v. Tyson, 129 Conn. 211 (1942); Constanza v. Verona, 48 N.J.

11980–1980
Rotch v. Rotch green
· 1899
1 sentence

1963Rotch v. Rotch, 173 Mass. 125, 131-133 .

11963–1963
Leverett v. Barnwell green
· 1913
1 sentence

1938The strict provisions of the spendthrift clause (12) and the fact that the discretion reposed in the trustee under clause nine was not absolute and uncontrolled, as in Leverett v. Barnwell, 214 Mass. 105 , give weight to this view.

11938–1938
Erickson v. Erickson green
minn · 1936
1 sentence

1938In general we prefer the reasoning in Erickson v. Erickson, 197 Minn. 71, 77-79 .

11938–1938

Statutes the citing opinions construe

MA § Mass. Gen. Laws ch. 208, § 34 (6)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

PA 25 (1915–2020) MA 13 (1938–2018) IL 11 (1940–2021) CA 9 (1938–2016) IA 6 (2004–2022) TX 6 (1971–2018) MN 4 (1943–2014) UT 4 (1989–2024) MO 4 (1973–2023) NY 3 (1967–2005) CO 3 (1991–2026) DE 3 (1960–2018) ME 3 (2003–2012) MD 2 (1988–2003) AZ 2 (2014–2014) GA 2 (1993–2010) AR 2 (2004–2016) OR 2 (1960–2018) MI 2 (1984–2025) HI 2 (1955–1964) WA 2 (1981–2016)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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